Mayflower District Court
#npz_v-robertsabbatini-v-mayflower-department-of-state-lorens20181
This is the start of #npz_v-robertsabbatini-v-mayflower-department-of-state-lorens20181 channel.
clerkFlow Bot2025-09-11 03:00 p.m.
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CV-444-25clerkFlow pinned a message to this channel.2026-01-18 02:59 p.m.
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Case Modified
Ian 2025-09-11 06:24 p.m.@cabot hello your honor
Ian 2025-09-11 06:24 p.m.
I’ll send the complaint shortly
Chancellor Cabot ᴘᴄ 2025-09-11 06:38 p.m.
ty
shah_khaled ᴘᴄ 2025-09-12 09:50 a.m.@Ian complaint
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Ian 2025-09-12 02:58 p.m.@cabot @krm sorry whole discord thing delayed this a little bit
Ian 2025-09-12 02:58 p.m.
Ill submit asap
Ian 2025-09-12 09:36 p.m.CLAIMANTS' ADMINISTRATIVE COMPLAINT
https://drive.google.com/file/d/1JCU7HG4jX_eXwHCaxtHU2oJuu6prUKL9/view?usp=sharing
Ian 2025-09-12 09:37 p.m.CLAIMANTS' EMERGENCY MOTION FOR TEMPORARY RESTRAINING ORDER
https://drive.google.com/file/d/1RGM0o-ovS7I9f1CZcr1oz-5EbXudNEWC/view?usp=sharing
Ian 2025-09-12 09:40 p.m.
49.73 KB
Ian 2025-09-12 09:41 p.m.@cabot @krm
Ian 2025-09-12 09:41 p.m.
Im actually so very sorry for the delay I almost pulled an awesomeplays
Ian 2025-09-12 09:41 p.m.
please rule on TRO asap and lmk and whatever
Ian 2025-09-12 09:42 p.m.
actually Ill draft proposed order
IanIan 2025-09-12 09:49 p.m.
Evidence
Ian 2025-09-12 09:50 p.m.
first document downloadable and viewable on browser—it's a transcript of our communications with DOS up to the moment they decided to do this
Ian 2025-09-12 10:00 p.m.CLAIMANTS' PROPOSED ORDER : : TEMPORARY RESTRAINING ORDER
https://drive.google.com/file/d/1AHCDlNbDC6i8KjPcw2GV2a_HQNkKmk0E/view?usp=sharing
Chancellor Cabot ᴘᴄ 2025-09-12 10:17 p.m.
Thanks
Chancellor Cabot ᴘᴄ 2025-09-12 10:19 p.m.
I'm not satisfied that this meets the threshold test for a TRO and irreparable harm is really not satisfied here, the court can easily rectify the challenged matter here with declaratory relief in a final order. E.g., It doesn't entail any deprivation of property that you would then struggle to recover if an adverse judgment were issued.
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Chancellor Cabot ᴘᴄI'm not satisfied that this meets the threshold test for a TRO and irreparable harm is really not satisfied here, the court can easily rectify the challenged matter here with decla...
Ian 2025-09-12 10:20 p.m.
If I may your honor I have to disagree
Ian 2025-09-12 10:21 p.m.
Under Herb Reed Enterprises loss of business reputation and goodwill alone is irreparable harm—our inability to operate with DOS undermining our very legitimacy creates immense doubt in our clients for which monetary damages are not sufficient to redress
Ian 2025-09-12 10:23 p.m.
Additionally, a business license as a means of occupation (we’re a law firm, and we’re lawyers) is a constitutionally protected interest. Compare this to Bell —there, the revocation of a mere driver’s license without procedural due process is irreparable harm. Imagine a business’ entire ability to function being on the line. Clearly, it’s irreparable
Ian 2025-09-12 10:24 p.m.
There are reparable damages that we can seek. For example, we can file a subsequent civil suit seeking lost wages
Ian 2025-09-12 10:24 p.m.
But the main issue is the irreparable harm that has already unquestionably ensued, we want to stop it
Chancellor Cabot ᴘᴄ 2025-09-12 10:26 p.m.
Listen to me
Chancellor Cabot ᴘᴄ 2025-09-12 10:26 p.m.
I am telling you it is not
Chancellor Cabot ᴘᴄ 2025-09-12 10:27 p.m.
You speak, I rule, I'm the judge
Chancellor Cabot ᴘᴄ 2025-09-12 10:27 p.m.
There is no room nor do I care to hear your disagreements
Chancellor Cabot ᴘᴄ 2025-09-12 10:27 p.m.
This is not an academic forum where we hold a tea party and explain our disagreements and work out a compromise
Chancellor Cabot ᴘᴄ 2025-09-12 10:28 p.m.
I am telling you my ruling and you accept it or you find a way to appeal when final judgment is given
Chancellor Cabot ᴘᴄ 2025-09-12 10:28 p.m.
Considering TRO's cannot be interlocutory appealed my word is final, you can present your request again with new argumentation and facts that would change my current position if we get to a preliminary injunction hearing
Ian 2025-09-12 10:29 p.m.
Understood, your honor
Chancellor Cabot ᴘᴄ 2025-09-12 10:38 p.m.
Also I am going to address what you stated in relation to HRE, that was an IP case which is completely different to the irreparable harm in a corporate case. IP usage carries immense economic value which simply cannot be recovered if used and produces a gain (i.e., Coca Cola losing their brand IP to Pepsi for a month, they lose more than just money but brand recognition, supply chains which will be gone forever etc).
That's just not the case here. I can simply issue an order that the DOS exceeded their powers and declare what I say to be so. The result would be that the business gets given back to the Ps. You're not claiming for economic gains made by D through this because its not reasonably calculable. There is no irreparable economic interest at hand. The simple fact that they are a business and produce money is not irreparable harm.
Also Bell quite literally invokes a separate substantive constitutional interest entirely different from HRE. Interstate travel (substantial public interest) v IP (substantial private economic interest which is unrecoverable) v a corporate deal (what is essentially the state facilitating a breach of private law obligations)
That's just not the case here. I can simply issue an order that the DOS exceeded their powers and declare what I say to be so. The result would be that the business gets given back to the Ps. You're not claiming for economic gains made by D through this because its not reasonably calculable. There is no irreparable economic interest at hand. The simple fact that they are a business and produce money is not irreparable harm.
Also Bell quite literally invokes a separate substantive constitutional interest entirely different from HRE. Interstate travel (substantial public interest) v IP (substantial private economic interest which is unrecoverable) v a corporate deal (what is essentially the state facilitating a breach of private law obligations)
Chancellor Cabot ᴘᴄ 2025-09-12 10:41 p.m.
Also there is a circuit split as to the requiring of evidence of irreparable harm where you're claiming an ecomomic interest justifies the imposition of a TRO: https://www.thebrandprotectionblog.com/2014/10/us-supreme-court-will-not-clarify-the-split-in-the-circuits-on-the-issue-of-presumption-of-irreparable-harm-in-trademark-preliminary-injunction-actions/
Chancellor Cabot ᴘᴄ 2025-09-12 10:42 p.m.
There is something that I believe would satisfy the fact there is irreparable harm here and a TRO would be appropriate but I can't litigate for you
robert 2025-09-12 10:45 p.m.
May I say something, Your Honor ?
robert 2025-09-12 10:45 p.m.@cabot
Chancellor Cabot ᴘᴄThere is something that I believe would satisfy the fact there is irreparable harm here and a TRO would be appropriate but I can't litigate for you
Ian 2025-09-12 10:51 p.m.
Something having to do with control of the business I’d assume
robertMay I say something, Your Honor ?
Chancellor Cabot ᴘᴄ 2025-09-12 10:52 p.m.
Converse with your counsel and decide whether it is something that is necessary to state
IanSomething having to do with control of the business I’d assume
Chancellor Cabot ᴘᴄ 2025-09-12 10:54 p.m.
The specificity by which the DOS ordered the return of the business and the ability of P's to actually perform that order.
robert 2025-09-12 11:01 p.m.
ok nevermind d/r
Chancellor Cabot ᴘᴄThe specificity by which the DOS ordered the return of the business and the ability of P's to actually perform that order.
Ian 2025-09-12 11:03 p.m.
Essentially you’d want me to show that DOS told us to give the business away and if that order isn’t blocked we lose control of the business
Ian 2025-09-12 11:04 p.m.
Yes I overlooked this, I may have believed it was implicit
Ian 2025-09-12 11:05 p.m.
I’ll raise it in the PI stage if I can
meowiitten 2025-09-12 11:11 p.m. 
meowiitten 2025-09-12 11:11 p.m.
1
Is this really necessary
1meowiitten 2025-09-12 11:11 p.m.
Jesus
meowiitten 2025-09-12 11:11 p.m.
Lmfaoooo
meowiitten 2025-09-12 11:11 p.m.
Eyesore
meowiitten 2025-09-12 11:14 p.m.@cabot Yeah it's my view that any injunctive relief before final judgment, like a TRO or preliminary injunction, would not be possible because it would have the effect of a final judgment (i.e., we cannot unhold a hearing). What he should do instead is file a motion for summary judgment on a preliminary injunction schedule(edited)
1
1Ian 2025-09-12 11:15 p.m.
We’re not at that stage
IanWe’re not at that stage
meowiitten 2025-09-12 11:15 p.m.
You can file a motion for summary judgment right now just brief on a PI schedule and do the discovery that you need
meowiitten 2025-09-12 11:16 p.m.
But it looks like there's quite a bit of discovery so
meowiitten 2025-09-12 11:16 p.m.
Seems like this involves questions of fact rather than purely legal questions
meowiitten 2025-09-12 11:16 p.m.
So that would probably be premature
meowiitten 2025-09-12 11:16 p.m.
I'm just saying it is possible to go straight to summary judgment if the case involves purely legal questions
meowiittenI'm just saying it is possible to go straight to summary judgment if the case involves purely legal questions
Ian 2025-09-12 11:18 p.m.
It’s purely legal questions in my opinion
Ian 2025-09-12 11:19 p.m.
But either way summary judgment is a no no until discovery
IanBut either way summary judgment is a no no until discovery
meowiitten 2025-09-12 11:19 p.m.
That's just not true
meowiitten 2025-09-12 11:19 p.m.
Look at Wilcox v. Trump
meowiitten 2025-09-12 11:19 p.m.
Their discovery was a single document and the defendants didn't file an answer or an mtd
meowiitten 2025-09-12 11:19 p.m.
They did it before that
IanIt’s purely legal questions in my opinion
meowiitten 2025-09-12 11:20 p.m.
Also I disagree because you're asking the court to overturn a finding of wrongdoing
meowiitten 2025-09-12 11:21 p.m.
You could move for partial summary judgment on count one
meowiitten 2025-09-12 11:21 p.m.
Count two involves a lot of different facts
meowiitten 2025-09-12 11:21 p.m.
But if you get a ruling in your favor on count one you don't need to proceed to count two because it would be dispensed with
Ian 2025-09-12 11:21 p.m.
Count two really only involves that we asked for evidence and DOS refused
Ian 2025-09-12 11:22 p.m.
It’s like two messages
meowiittenBut if you get a ruling in your favor on count one you don't need to proceed to count two because it would be dispensed with
Ian 2025-09-12 11:22 p.m.
True, yes
meowiitten 2025-09-12 11:22 p.m.
So do a motion for summary judgment briefed on a PI schedule for count one and we will do a cross-motion
meowiitten 2025-09-12 11:22 p.m.
Or both, I don't care
meowiitten 2025-09-12 11:22 p.m.
Just to get it over with
Ian 2025-09-12 11:22 p.m.
Wilcox v Trump happened because there were minimal facts
meowiitten 2025-09-12 11:23 p.m.
That's what I said
meowiitten 2025-09-12 11:23 p.m.
But you see I am not objecting to you moving for summary judgment
Ian 2025-09-12 11:23 p.m.
Yes, but here, while the questions are all of law, there are (undisputed) facts
Ian 2025-09-12 11:23 p.m.
I mean
Ian 2025-09-12 11:23 p.m.
They will be undisputed
Ian 2025-09-12 11:23 p.m.
They require discovery
meowiitten 2025-09-12 11:24 p.m.
Okay how about this
meowiitten 2025-09-12 11:24 p.m.
Move for partial summary judgment on count one
meowiitten 2025-09-12 11:24 p.m.
Thats a purely legal question
meowiitten 2025-09-12 11:24 p.m.
And we will file a cross-motion
meowiitten 2025-09-12 11:24 p.m.
Because the case is over if count one is decided for you
meowiitten 2025-09-12 11:24 p.m.
If count one is decided in our favor then the case continues on whether there was wrongdoing
meowiitten 2025-09-12 11:24 p.m.
But that we had the ability to adjudicate
Ian 2025-09-12 11:25 p.m.
I would love to if the facts were undisputed
Ian 2025-09-12 11:25 p.m.
You haven’t even filed a response
meowiitten 2025-09-12 11:25 p.m.
There's no facts on count one...
meowiitten 2025-09-12 11:25 p.m.
Dude
meowiitten 2025-09-12 11:25 p.m.
I'm trying to help you out no bullshit
meowiittenThere's no facts on count one...
Ian 2025-09-12 11:25 p.m.
There are though
meowiitten 2025-09-12 11:25 p.m.
Work laterally
meowiitten 2025-09-12 11:26 p.m.
Okay then I'm just going to move to dismiss now
meowiitten 2025-09-12 11:26 p.m.
I don't care
Ian 2025-09-12 11:26 p.m.
Ok you do that
Ian 2025-09-12 11:26 p.m.
I’ll see if there’s facts in count one tomorrow rn Im going to sleep
Ian 2025-09-12 11:26 p.m.
Im pretty sure there are though
meowiittenBut that we had the ability to adjudicate
Chancellor Cabot ᴘᴄ 2025-09-13 06:59 a.m.
I would agree with this
Ian 2025-09-13 08:35 a.m.
Ok great I’ll work on that
Ian 2025-09-13 04:04 p.m.@cabot can I wait till a response
Ian 2025-09-13 04:04 p.m.
I feel like
Ian 2025-09-13 04:04 p.m.
It will make things less complicated
Chancellor Cabot ᴘᴄ 2025-09-13 05:57 p.m.
Hi are you filing a response too or is your MTD (functionally) your response(edited)
Chancellor Cabot ᴘᴄ 2025-09-13 05:57 p.m.
Fed Civ Pro irl allow for MTD's to serve as responses if the defense counsel chooses right(edited)
Chancellor Cabot ᴘᴄ 2025-09-13 05:57 p.m.
Did I make that up
Chancellor Cabot ᴘᴄ 2025-09-13 05:57 p.m.@meowiitten
Chancellor Cabot ᴘᴄFed Civ Pro irl allow for MTD's to serve as responses if the defense counsel chooses right(edited)
meowiitten 2025-09-13 05:58 p.m.
So basically its like
meowiitten 2025-09-13 05:58 p.m.
MTD can stall the answer timer
meowiitten 2025-09-13 05:58 p.m.
If its denied
meowiitten 2025-09-13 05:58 p.m.1
And then they usually get the time they lost back
1Ian 2025-09-13 06:08 p.m.@cabot
Ian 2025-09-13 06:08 p.m.
sado has not submitted an MTD nor a response
Ian 2025-09-13 06:08 p.m.
and it's due in a couple hours
Ian 2025-09-13 06:08 p.m.
bc you get 1 day in administrative procedures
Ian 2025-09-13 06:09 p.m.
Mayf. R. Adm. P. 10(a).
Chancellor Cabot ᴘᴄ 2025-09-13 06:09 p.m.
Oh I see tolling
Chancellor Cabot ᴘᴄ 2025-09-13 06:09 p.m.
Interesting
Chancellor Cabot ᴘᴄ 2025-09-13 06:09 p.m.
So why is this an administrative proceeding again
Ian 2025-09-13 06:09 p.m.
we're contesting an administrative action
Chancellor Cabot ᴘᴄ 2025-09-13 06:10 p.m.
But is this administrative in the sense and purpose of the rules
Chancellor Cabot ᴘᴄ 2025-09-13 06:10 p.m.
Because administrative in my mind and what most of the statutes indicate is that an administrative action is one that is disciplinary and exercised against subordinates
Chancellor Cabot ᴘᴄ 2025-09-13 06:11 p.m.
And are the causes of action not specified for administrative actions before the admin court? I.e., employment challenges, disciplinary matters and whether a rule is arbitrary and capricious
Chancellor Cabot ᴘᴄ 2025-09-13 06:12 p.m.
Your complaint reads like a normal tort cause of action
Ian 2025-09-13 06:12 p.m.
Disciplinary action against a state employee is one of many administrative actions an agency can take that can then be contested in court
Chancellor Cabot ᴘᴄ 2025-09-13 06:12 p.m.
Where is our administrative procedures act
Ian 2025-09-13 06:12 p.m.
But generally any administrative action an agency takes (where art III jurisdiction is proper) is one that can be contested in admin court
Ian 2025-09-13 06:12 p.m.
we don't have one
Ian 2025-09-13 06:12 p.m.
we only have the rules, and the fact that the court retains jurisdiction over administrative matters
Ian 2025-09-13 06:13 p.m.
so there's like no structure besides the arguably vague rules
Ian 2025-09-13 06:13 p.m.
Which is why I was expecting this to be of a more fluid dynamic, I'm not sure if you'd concur
Ian 2025-09-13 06:13 p.m.
you can set your own guidelines as to how this will proceed
Chancellor Cabot ᴘᴄWhere is our administrative procedures act
meowiitten 2025-09-13 06:13 p.m.
They can only do a non-statutory review action basically if the underlying act was unconstitutional
meowiitten 2025-09-13 06:13 p.m.
Leedom v kyne standard
meowiitten 2025-09-13 06:14 p.m.
Frankly if this is about whether the DOS can resolve licensing disputes and I only have like 2 hours to respond I'm not gonna get my panties in a bunch over this
Ian 2025-09-13 06:14 p.m.
sado do you wanna do a consent judgment
meowiitten 2025-09-13 06:14 p.m.1
We can run out the default clock and then cabot will not be able to rule in your favor on count one
1meowiitten 2025-09-13 06:14 p.m.
No I don't
meowiittenWe can run out the default clock and then cabot will not be able to rule in your favor on count one
Ian 2025-09-13 06:14 p.m.
you mean he will be able
meowiitten 2025-09-13 06:14 p.m.
No he won't be able
meowiitten 2025-09-13 06:15 p.m.
He still has to find that he can grant the relief
meowiitten 2025-09-13 06:15 p.m.
It's just that I don't get a chance to contest it
meowiittenHe still has to find that he can grant the relief
Ian 2025-09-13 06:15 p.m.
that's in civil actions
Ian 2025-09-13 06:15 p.m.
not administrative
Ian 2025-09-13 06:15 p.m.
These are the administrative default rules
meowiitten 2025-09-13 06:15 p.m.1
You are in a court of equity sir
1meowiitten 2025-09-13 06:16 p.m.
You are asking for equitable remedies and collaterally challenging the DOS's authority to resolve disputes at all
Ian 2025-09-13 06:16 p.m.
true
Ian 2025-09-13 06:16 p.m.
Yes
Ian 2025-09-13 06:16 p.m.
But in default he will find that he can grant the relief and that it is proper
meowiitten 2025-09-13 06:16 p.m.
I'm okay to let him do that
Ian 2025-09-13 06:17 p.m.
If you're just going to do that why do you not want a consent judgment
meowiitten 2025-09-13 06:17 p.m.
If I have like 3 hours I'm taking calc notes I don't have the time to write anything up
Chancellor Cabot ᴘᴄ 2025-09-13 06:17 p.m.
What's the problem with me granting relief again(edited)
Ian 2025-09-13 06:17 p.m.
you'll essentially be ruling that DOS cannot adjudicate controversies anymore
Ian 2025-09-13 06:17 p.m.
Which is obviously completely a good thing
meowiitten 2025-09-13 06:17 p.m.
Nga
meowiitten 2025-09-13 06:17 p.m.
How
Chancellor Cabot ᴘᴄ 2025-09-13 06:17 p.m.
Uh I'm not going to do that
Ian 2025-09-13 06:17 p.m.
Because it's ultra vires and in excess of their authority
meowiitten 2025-09-13 06:17 p.m.
Who do they go to to regulate licenses?
Chancellor Cabot ᴘᴄ 2025-09-13 06:18 p.m.
I think that claim is particularly weak ngl
Ian 2025-09-13 06:18 p.m.
DOS has only two responsibilities in commerce
Ian 2025-09-13 06:18 p.m.
firstly promulgating regulations
Ian 2025-09-13 06:18 p.m.
secondly keeping records
Ian 2025-09-13 06:18 p.m.
they can't decide who owns a particular piece of private property that's inherently a judicial function
Chancellor Cabot ᴘᴄ 2025-09-13 06:18 p.m.
Well why can't I just say they exceeded their powers, I don't need to go into SOP fufu about cases and controversies
Ian 2025-09-13 06:18 p.m.
you can do that I dont mind
Ian 2025-09-13 06:19 p.m.
Yes
meowiitten 2025-09-13 06:19 p.m.1
So they should be able to promulgate regulations but not enforce them
1Ian 2025-09-13 06:19 p.m.
I'd like it if we could begin the default proceedings now since sado has already said he won't submit anything and will let default trigger
meowiittenSo they should be able to promulgate regulations but not enforce them
Ian 2025-09-13 06:19 p.m.
Uh no
meowiitten 2025-09-13 06:19 p.m.
How would they enforce them if not through an adjudicative process
Ian 2025-09-13 06:19 p.m.
They can enforce regulations
Chancellor Cabot ᴘᴄ 2025-09-13 06:19 p.m.
What regulation was at stake here
meowiitten 2025-09-13 06:19 p.m.
Do you want zero process?
Ian 2025-09-13 06:19 p.m.
But who owns something is not a regulation
Ian 2025-09-13 06:19 p.m.
They can't determine who owns a particular piece of private property
Chancellor Cabot ᴘᴄWhat regulation was at stake here
meowiitten 2025-09-13 06:19 p.m.
Their power to enforce them at all
meowiitten 2025-09-13 06:19 p.m.
Not regulations specifically
Ian 2025-09-13 06:20 p.m.
They can determine if somebody broke a commercial regulation, yes. They can't determine who owns something
Chancellor Cabot ᴘᴄWhat regulation was at stake here
Ian 2025-09-13 06:20 p.m.
No regulation lol
meowiitten 2025-09-13 06:20 p.m.
That is...
meowiitten 2025-09-13 06:20 p.m.1
paradoxical
1Ian 2025-09-13 06:20 p.m.
They decided to just tell me who owns something
Ian 2025-09-13 06:20 p.m.
Even though they're DOS not a court
Ian 2025-09-13 06:20 p.m.
We didn't break a regulation. A regulation wasn't cited.
Chancellor Cabot ᴘᴄ 2025-09-13 06:21 p.m.
Well I'm not sure this implicates their enforcement powers at all
Ian 2025-09-13 06:21 p.m.
DOS decided to use their ministerial purpose of record keeping commercial information to adjudicate a controversy of private property ownership
Chancellor Cabot ᴘᴄWell I'm not sure this implicates their enforcement powers at all
Ian 2025-09-13 06:21 p.m.
It doesn't, I don't know what sado means
Ian 2025-09-13 06:21 p.m.
They just can't tell me who owns my business
Ian 2025-09-13 06:21 p.m.
Their little
owner:Ian 2025-09-13 06:21 p.m.
it's not legally binding
Ian 2025-09-13 06:21 p.m.
ownership is according to the law, not what DOS says
meowiitten 2025-09-13 06:22 p.m.
Okay but you clearly said in count one they have no enforcement power
Ian 2025-09-13 06:22 p.m.
I did not say that
meowiitten 2025-09-13 06:22 p.m.
I don't even care about the other part whether it was wrong or right
Ian 2025-09-13 06:22 p.m.
I said they couldn't adjudicate controversies of private property ownership
Ian 2025-09-13 06:22 p.m.
they can't
Chancellor Cabot ᴘᴄ 2025-09-13 06:22 p.m.
The only real issue is that this woman stuck her neck into a dispute that should have been left for litigation
meowiitten 2025-09-13 06:23 p.m. 
2
2Chancellor Cabot ᴘᴄ 2025-09-13 06:23 p.m.
Actually I guess I kind of see how it involves SOP but I feel like there's a better way to frame the claim than SOP since the relationship is barely causal
meowiittenClick to see attachment.
Ian 2025-09-13 06:23 p.m.
30 is correct
Ian 2025-09-13 06:23 p.m.
29 I think I miswrote it
meowiitten 2025-09-13 06:23 p.m.
Really?
Ian 2025-09-13 06:23 p.m.
nope
Ian 2025-09-13 06:23 p.m.
I didnt miswrite it
Ian 2025-09-13 06:23 p.m.
I said
Ian 2025-09-13 06:23 p.m.
DOS has two responsibilities: promulgating and enforcing commercial regulations, and record keeping
Ian 2025-09-13 06:24 p.m.
besides intellectual property, they have no other authority
meowiitten 2025-09-13 06:24 p.m.
Let me go tell the DOS to de-register all business and overturn all suspensions why don't we all just fuck off then
meowiitten 2025-09-13 06:24 p.m.
Alright mate
Ian 2025-09-13 06:24 p.m.
they can't tell people who owns a business
meowiittenLet me go tell the DOS to de-register all business and overturn all suspensions why don't we all just fuck off then
Ian 2025-09-13 06:24 p.m.
That's literally not what Im saying
Ian 2025-09-13 06:24 p.m.
you can enforce your regulations
Ian 2025-09-13 06:24 p.m.
You cant tell me who owns my business though
Ian 2025-09-13 06:24 p.m.
Because a business is private property subject to the law in how it is transferred
meowiitten 2025-09-13 06:24 p.m.
The license goes to a person
Ian 2025-09-13 06:24 p.m.
Not what DOS says
meowiittenThe license goes to a person
Ian 2025-09-13 06:24 p.m.
The license goes to a business, actually
Ian 2025-09-13 06:24 p.m.
that's how it's structured
Ian 2025-09-13 06:24 p.m.
What's your point?
meowiitten 2025-09-13 06:25 p.m.
Agency???
Chancellor Cabot ᴘᴄ 2025-09-13 06:25 p.m.
Actually I guess I can just say that it didn't fall into the mandate to ensure fair market practices are maintained, ethical practices are maintained and that businesses operate within the scope of state law right
Ian 2025-09-13 06:25 p.m.
What?
Chancellor Cabot ᴘᴄActually I guess I can just say that it didn't fall into the mandate to ensure fair market practices are maintained, ethical practices are maintained and that businesses operate wi...
Ian 2025-09-13 06:25 p.m.
Obviously it didn't but in general adjudicating controversies about ownership, even if it's about ownership of a business, is a duty reserved to the judicial department
meowiitten 2025-09-13 06:25 p.m.
What is an entity without agency, the people who make up the entity. Who renews the entity's license? An agent
Ian 2025-09-13 06:26 p.m.
sado what
Ian 2025-09-13 06:26 p.m.
what's your point here
meowiitten 2025-09-13 06:26 p.m.
It's to a person for the purpose of an entity
meowiitten 2025-09-13 06:26 p.m.
They can determine which person the license is entitled to
Ian 2025-09-13 06:26 p.m.
uh no they can't
Ian 2025-09-13 06:26 p.m.
Business licenses are granted to the business to operate
Ian 2025-09-13 06:26 p.m.
Besides that their role is record keeping
Ian 2025-09-13 06:26 p.m.
They keep records, that's it
Ian 2025-09-13 06:27 p.m.@cabot
meowiitten 2025-09-13 06:27 p.m.
Whatever I don't care how the dispute about ownership ends just don't tell DOS they can't enforce their rules
Ian 2025-09-13 06:27 p.m.
Literally nobody is saying you can't enforce your rules
meowiitten 2025-09-13 06:28 p.m.
Just possibly that DOS exceeded their authority in naming the head of the entity
Ian 2025-09-13 06:28 p.m.
I said that already
Ian 2025-09-13 06:28 p.m.
I'm just saying you can't tell people who their business belongs to
Ian 2025-09-13 06:28 p.m.
If there is a dispute, you tell the person to sue
meowiitten 2025-09-13 06:28 p.m.
Well sure that should be a seperate lawsuit
Ian 2025-09-13 06:28 p.m.
You don't adjudicate and play judge
Ian 2025-09-13 06:28 p.m.
because you're not
meowiitten 2025-09-13 06:28 p.m.
That should be a case for declaratory relief
Ian 2025-09-13 06:28 p.m.
Sado are you just now getting it
Ian 2025-09-13 06:28 p.m.
Yes
Ian 2025-09-13 06:28 p.m.
That's what I've been saying all along
meowiitten 2025-09-13 06:28 p.m. 
2
2meowiitten 2025-09-13 06:28 p.m.
Buddy
Ian 2025-09-13 06:28 p.m.1
If Hamilton wanted the business, he should've sued under DJA
1meowiitten 2025-09-13 06:28 p.m.
This is not what you've been saying
meowiittenClick to see attachment.
Ian 2025-09-13 06:29 p.m.
DOS can't investigate CONTROVERSIES
Ian 2025-09-13 06:29 p.m.
I didn't say DOS can't investigate commercial regulation violations
meowiitten 2025-09-13 06:29 p.m. 
Ian 2025-09-13 06:29 p.m.
because they can
Ian 2025-09-13 06:29 p.m.
they can't investigate CONTROVERSIES though they are not JUDGES
meowiitten 2025-09-13 06:29 p.m.
The switch up is crazy
Chancellor Cabot ᴘᴄ 2025-09-13 06:29 p.m.
ijbol
meowiitten 2025-09-13 06:29 p.m.
Whatever I default. Do whatever you want
Chancellor Cabot ᴘᴄ 2025-09-13 06:29 p.m.
meowiitten 2025-09-13 06:29 p.m.
4
I consent to default
4meowiittenClick to see attachment.
Ian 2025-09-13 06:30 p.m.
Controversy between two people as to ownership ≠ violation of commercial regulations
Ian 2025-09-13 06:30 p.m.
you can investigate violations of regulations
Chancellor Cabot ᴘᴄ 2025-09-13 06:30 p.m.
okay wheres the discovery doc bud
Ian 2025-09-13 06:30 p.m.
you can't adjudicate controversies
Chancellor Cabot ᴘᴄ 2025-09-13 06:30 p.m.
also can you create a text flowchart telling me what happened when
Chancellor Cabot ᴘᴄalso can you create a text flowchart telling me what happened when
Ian 2025-09-13 06:30 p.m.
just download and open this in your browser
Chancellor Cabot ᴘᴄ 2025-09-13 06:30 p.m.
meowiitten 2025-09-13 06:30 p.m.
SQL injector ass shit
Ian 2025-09-13 06:30 p.m.1
I promise it's not a virus
1Ian 2025-09-13 06:31 p.m.
lmao
Ian 2025-09-13 06:31 p.m.
it's a transcript like the ones used in transcripts
Ian 2025-09-13 06:31 p.m.
of the GC
Ian 2025-09-13 06:31 p.m.
exactly same code
Chancellor Cabot ᴘᴄ 2025-09-13 06:31 p.m.
just ask chatgpt to make something like this for me to easily read dates times and events so i can write tmrw
i.e., date, hamilton sells business, see ex a >> date, next action, see ex b >> continues on
i.e., date, hamilton sells business, see ex a >> date, next action, see ex b >> continues on
Chancellor Cabot ᴘᴄ 2025-09-13 06:32 p.m.
i hate doubled spaced text when trying to find events
Chancellor Cabot ᴘᴄ 2025-09-13 06:32 p.m.
make infographics 
Ian 2025-09-13 06:32 p.m.
Do I need to include the dates everywhere
Ian 2025-09-13 06:33 p.m.
How about if I just name every factual allegation paragraph in my complaint and direct you to where the proof for that paragraph is @cabot
Ian 2025-09-13 06:33 p.m.
like
Ian 2025-09-13 06:34 p.m.
28 >> ex. A, B
29 >> ex. B
30 >> ex. C
31 >> ex. C
32 >> ex. C, D
33 >> ex. D
29 >> ex. B
30 >> ex. C
31 >> ex. C
32 >> ex. C, D
33 >> ex. D
Chancellor Cabot ᴘᴄ 2025-09-13 06:34 p.m.
sure but you still need to disclose the evidence you have for this stuff in an appendix right
Ian 2025-09-13 06:35 p.m.
can I send that in a message too
Chancellor Cabot ᴘᴄ 2025-09-13 06:35 p.m.
sure
Ian 2025-09-13 06:37 p.m.
Am I allowed to send some of the evidence in html format @cabot for easy viewability
Ian 2025-09-13 06:37 p.m.
actually I think I can convert it to pdf
Ian 2025-09-13 06:37 p.m.
nope but Ill send .txt
Chancellor Cabot ᴘᴄ 2025-09-13 06:38 p.m.
Chancellor Cabot ᴘᴄ 2025-09-13 06:38 p.m.
what is this evidence
Chancellor Cabot ᴘᴄwhat is this evidence
Ian 2025-09-13 06:38 p.m.
channel transcript
Ian 2025-09-13 06:39 p.m.
our communication with DOS
Ian 2025-09-13 06:44 p.m.EVIDENCE APPENDIX
A - [Our communications with DOS](https://pastebin.com/raw/nk38f9t4)
B - [DOS Trello page of Clerion Legal a/k/a Hamilton & Wexler](https://drive.google.com/file/d/1FFMjZLh2HxIbEJ1cgB7B9HC4b_CwRaNs/view?usp=sharing)
C - [Document supplied by RobertSabbatini in proving his ownership of H&W a/k/a Clerion Legal](https://docs.google.com/document/d/1MqqJErsQzRz-zX8OEocJv7Of7YUSkFJpl9OkiOXZMcU/edit?usp=sharing)(edited)To: Department of State, Business Licensing Division (Case #139) From: RobertSabbatini, Managing Partner, Clerion Legal Date: August 22nd, 2025 Hi Assistant Secretary of State, I write to formally respond to the allegations in Case #139, which claim that I, RobertSabbatini, misrepresented my ow... 
1
A - [Our communications with DOS](https://pastebin.com/raw/nk38f9t4)
B - [DOS Trello page of Clerion Legal a/k/a Hamilton & Wexler](https://drive.google.com/file/d/1FFMjZLh2HxIbEJ1cgB7B9HC4b_CwRaNs/view?usp=sharing)
C - [Document supplied by RobertSabbatini in proving his ownership of H&W a/k/a Clerion Legal](https://docs.google.com/document/d/1MqqJErsQzRz-zX8OEocJv7Of7YUSkFJpl9OkiOXZMcU/edit?usp=sharing)(edited)
1Ian 2025-09-13 06:52 p.m.WITNESS LIST
Lay - RobertSabbatini
Lay - Lorens20181
Lay - JamesMHamilton
Lay - npz_v
Lay - RobertSabbatini
Lay - Lorens20181
Lay - JamesMHamilton
Lay - npz_v
Ian 2025-09-13 06:52 p.m.FACTS
7. Ex. B.
8. Testimony (JamesMHamilton, RobertSabbatini).
9. Ex. C & Testimony (JamesMHamilton, RobertSabbatini).
10. Ex. B, C, & Testimony (JamesMHamilton, RobertSabbatini, npz_v, Lorens20181).
11. Testimony (npz_v, RobertSabbatini).
12. Ex. A & Testimony (JamesMHamilton, RobertSabbatini, npz_v).
13. Ex. A & Testimony (RobertSabbatini, Lorens20181)
14. Ex. A & Testimony (RobertSabbatini, Lorens20181)
15. Ex. A.
16. Ex. A.
17. Ex. A.
18. Ex. A.
19. Ex. A.
20. Ex. A.
21. Ex. A & C.
22. Ex. A.
23. Ex. A.
24. Ex. A.
25. Ex. B & Testimony (RobertSabbatini, Lorens20181, JamesMHamilton, npz_v).1
7. Ex. B.
8. Testimony (JamesMHamilton, RobertSabbatini).
9. Ex. C & Testimony (JamesMHamilton, RobertSabbatini).
10. Ex. B, C, & Testimony (JamesMHamilton, RobertSabbatini, npz_v, Lorens20181).
11. Testimony (npz_v, RobertSabbatini).
12. Ex. A & Testimony (JamesMHamilton, RobertSabbatini, npz_v).
13. Ex. A & Testimony (RobertSabbatini, Lorens20181)
14. Ex. A & Testimony (RobertSabbatini, Lorens20181)
15. Ex. A.
16. Ex. A.
17. Ex. A.
18. Ex. A.
19. Ex. A.
20. Ex. A.
21. Ex. A & C.
22. Ex. A.
23. Ex. A.
24. Ex. A.
25. Ex. B & Testimony (RobertSabbatini, Lorens20181, JamesMHamilton, npz_v).
1Ian 2025-09-13 06:53 p.m.@cabot done
Chancellor Cabot ᴘᴄ 2025-09-13 06:53 p.m.
ty
Ian 2025-09-14 08:32 a.m.@cabot Please rule soon, sooner the better so I can keep working
Chancellor Cabot ᴘᴄ 2025-09-15 02:23 p.m.
Quiet
Chancellor Cabot ᴘᴄ 2025-09-15 02:24 p.m.
You are not doing any work right now, you are the equivalent of a pillow princess
meowiitten 2025-09-15 05:28 p.m.@cabot This case should be held in judgment I'm not sure how to phrase this but there's been a lot of misrepresentations made to the Court about how Clerion Legal came about
meowiitten 2025-09-15 05:28 p.m.
So much so that JamesMHamilton might need to intervene and initiate a claim against Clerion Legal
meowiittenChancellor Cabot ᴘᴄ 2025-09-15 05:36 p.m.
Is this true now..
Chancellor Cabot ᴘᴄ used /add
clerkFlow Bot2025-09-15 05:36 p.m. @cabot has added @huddy. to the case channel.
Case Modified
Chancellor Cabot ᴘᴄ 2025-09-15 05:36 p.m.
Hello
Chancellor Cabot ᴘᴄ 2025-09-15 05:36 p.m.@huddy.
meowiitten 2025-09-15 05:36 p.m.
I will say though he brought this to our attention not the other way around
meowiitten 2025-09-15 05:37 p.m.
Alright so just to preamble:
HW = Hamilton & Wexler. HW has never been a corporation. It has always been a Limited Liability Company. Furthermore, RobertSabbatini never actually signed an employment contract with me, let alone a partnership contract. Therefore, he has no legal claim. Is it odd that he never had an employment contract? Yes, but neither do most businesses as back then this was not common practice. Also by the way, I forgot that you can prosecute them also for running a business without a license lol.
Timeline:
January 19 - I setup the firm. I make the discord server and rank RobertSabbatini as a senior partner and myself as managing partner.
May 19 - I say 'im giving the firm to you today tempo, i have exams, you have a month
June 5 - He hasn't done anything with his temporary verbal ownership (no contracts signed), but he messages me saying 'indefinitely i take over the firm as managing partner and own the discord, and build it up materially and you stay as senior partner and take as many cases as you’d like as you’re extremely talented. ' My response: 'are you retarded'. He t hen asks me for ownership of the discord server because hes paying for the bots and needs supreme access to manage the bot systems for technical stuff, so I Give him the discord. He uses a screenshot of that to get the state bar to lable him as ownership and get the state department to lable him as ownership.
The fact is simple. He has never been a partner legally, and has no legal right to claim the business. Even if he was, he would need a contract of me transferring ownership of the firm. I have never even orally stated that he could be legal registered owner.
As for criminal trademark, I personally own Hamilton & Wexler, Clerion Legal, HW Logo, Clerion Legal Logo and Clerion Legal description, all of which they are using.
As for operating a business without a license, that's a pretty simple one right there.
HW = Hamilton & Wexler. HW has never been a corporation. It has always been a Limited Liability Company. Furthermore, RobertSabbatini never actually signed an employment contract with me, let alone a partnership contract. Therefore, he has no legal claim. Is it odd that he never had an employment contract? Yes, but neither do most businesses as back then this was not common practice. Also by the way, I forgot that you can prosecute them also for running a business without a license lol.
Timeline:
January 19 - I setup the firm. I make the discord server and rank RobertSabbatini as a senior partner and myself as managing partner.
May 19 - I say 'im giving the firm to you today tempo, i have exams, you have a month
June 5 - He hasn't done anything with his temporary verbal ownership (no contracts signed), but he messages me saying 'indefinitely i take over the firm as managing partner and own the discord, and build it up materially and you stay as senior partner and take as many cases as you’d like as you’re extremely talented. ' My response: 'are you retarded'. He t hen asks me for ownership of the discord server because hes paying for the bots and needs supreme access to manage the bot systems for technical stuff, so I Give him the discord. He uses a screenshot of that to get the state bar to lable him as ownership and get the state department to lable him as ownership.
The fact is simple. He has never been a partner legally, and has no legal right to claim the business. Even if he was, he would need a contract of me transferring ownership of the firm. I have never even orally stated that he could be legal registered owner.
As for criminal trademark, I personally own Hamilton & Wexler, Clerion Legal, HW Logo, Clerion Legal Logo and Clerion Legal description, all of which they are using.
As for operating a business without a license, that's a pretty simple one right there.
Chancellor Cabot ᴘᴄ used /add
clerkFlow Bot2025-09-15 05:37 p.m. @cabot has added @mantisshrimp69 to the case channel.
Case Modified
meowiittenAlright so just to preamble: HW = Hamilton & Wexler. HW has never been a corporation. It has always been a Limited Liability Company. Furthermore, RobertSabbatini never actually s...
meowiitten 2025-09-15 05:37 p.m.@cabot This
Chancellor Cabot ᴘᴄ 2025-09-15 05:39 p.m.
Uhm what the hell
May 19 - I say 'im giving the firm to you today tempo, i have exams, you have a month
June 5 - He hasn't done anything with his temporary verbal ownership (no contracts signed), but he messages me saying 'indefinitely i take over the firm as managing partner and own the discord, and build it up materially and you stay as senior partner and take as many cases as you’d like as you’re extremely talented. ' My response: 'are you retarded'. He t hen asks me for ownership of the discord server because hes paying for the bots and needs supreme access to manage the bot systems for technical stuff, so I Give him the discord. He uses a screenshot of that to get the state bar to lable him as ownership and get the state department to lable him as ownership.
The fact is simple.
May 19 - I say 'im giving the firm to you today tempo, i have exams, you have a month
June 5 - He hasn't done anything with his temporary verbal ownership (no contracts signed), but he messages me saying 'indefinitely i take over the firm as managing partner and own the discord, and build it up materially and you stay as senior partner and take as many cases as you’d like as you’re extremely talented. ' My response: 'are you retarded'. He t hen asks me for ownership of the discord server because hes paying for the bots and needs supreme access to manage the bot systems for technical stuff, so I Give him the discord. He uses a screenshot of that to get the state bar to lable him as ownership and get the state department to lable him as ownership.
The fact is simple.
Chancellor Cabot ᴘᴄUhm what the hell May 19 - I say 'im giving the firm to you today tempo, i have exams, you have a month June 5 - He hasn't done anything with his temporary verbal ownership (no co...
meowiitten 2025-09-15 05:39 p.m.
He hasn't given us physical evidence yet but I'm sure he will send it here
Chancellor Cabot ᴘᴄ 2025-09-15 05:40 p.m.
I hope you haven't breached your duty of candour buddy @mantisshrimp69
Chancellor Cabot ᴘᴄ 2025-09-15 05:41 p.m.
These two things can't be true at the same time can they
meowiitten 2025-09-15 05:42 p.m.
Well what I'm gonna do is just give you information as it comes to me and I guess these two needs to figure it out between themselves
mantisshrimp69 2025-09-15 05:42 p.m.
Hi
mantisshrimp69 2025-09-15 05:42 p.m.
What is the issue @cabot
mantisshrimp69 2025-09-15 05:42 p.m.
It seems sado is trying to say that we don’t have ownership rights to our business
mantisshrimp69 2025-09-15 05:42 p.m.
We do, but that’s irrelevant to this case
mantisshrimp69 2025-09-15 05:43 p.m.
This case is about how DOS can’t adjudicate it themselves, if Hamilton wants the business he needs to sue (in which case we will win)
Chancellor Cabot ᴘᴄI hope you haven't breached your duty of candour buddy @mantisshrimp69
mantisshrimp69 2025-09-15 05:44 p.m.
Of course not
mantisshrimp69 2025-09-15 05:44 p.m.
What two things?
mantisshrimp69 2025-09-15 06:25 p.m.@cabot what two things can't be true at the same time
mantisshrimp69 2025-09-15 06:26 p.m.
Oh the message before that
mantisshrimp69 2025-09-15 06:27 p.m.
ok my bad I did not see what sado sent
meowiittenAlright so just to preamble: HW = Hamilton & Wexler. HW has never been a corporation. It has always been a Limited Liability Company. Furthermore, RobertSabbatini never actually s...
mantisshrimp69 2025-09-15 06:27 p.m.
am I required to evaluate this
mantisshrimp69 2025-09-15 06:28 p.m.
if it contradicts our statement of facts, then I can loudly say it's a lie
mantisshrimp69 2025-09-15 06:28 p.m.
but I don't think I have to because again this isn't an action to determine the true owner of Clerion
mantisshrimp69 2025-09-15 06:28 p.m.
(though if @huddy. keeps spreading lies I might have to sue him for declaratory judgment...)
mantisshrimp69 2025-09-15 06:28 p.m.
this is an action to determine that DOS cannot adjudicate a controversy of ownership—he has to sue for that. DOS can't do it for him, that's not how our constitution works
mantisshrimp69 2025-09-15 06:29 p.m.
I'll say, regaradless, that this action is 100% brought bona fide in good faith
mantisshrimp69 2025-09-15 06:30 p.m.
and to the best of my knowledge should hamilton properly bring about an action in court, as opposed to crying to an administrative agency with no such jurisdiction to do so, we will win and he will lose
meowiitten 2025-09-15 06:32 p.m.
I’m just giving what I received
mantisshrimp69 2025-09-15 06:32 p.m.
No, you're deliberately trying to unduly influence the court with impertinent statements that don't belong here
meowiitten 2025-09-15 06:33 p.m.
mantisshrimp69 2025-09-15 06:33 p.m.
It's a desperate and pathetic attempt of trying to sway the court into allowing you a more favorable resolution because you are in default
meowiitten 2025-09-15 06:37 p.m.
mantisshrimp69 2025-09-15 06:37 p.m.@cabot was he not put in contempt just minutes ago for similar conduct
mantisshrimp69 2025-09-15 06:38 p.m.
I would move for sanctions if you deem them appropriate
mantisshrimp69 2025-09-15 06:38 p.m.
this conduct is unbecoming for the attorney general of the state
Chancellor Cabot ᴘᴄ 2025-09-15 06:58 p.m.
I didn't understand a word he said
meowiitten 2025-09-15 07:04 p.m. 3
3meowiitten 2025-09-15 07:05 p.m.@cabot I hope this helps you
meowiitten 2025-09-15 07:07 p.m.
Summon the IAS officer Please
meowiitten 2025-09-15 07:07 p.m.@singhski @singhski
Chancellor Cabot ᴘᴄ 2025-09-15 07:18 p.m.
Translate @singhski
vloqsouls 2025-09-15 07:21 p.m.
Hi sorry Singhski couldn't make it
meowiittenClick to see attachment.
vloqsouls 2025-09-15 07:23 p.m.
Autism
mantisshrimp69 2025-09-15 10:22 p.m.@cabot pillow princess here
mantisshrimp69 2025-09-15 10:22 p.m.
Can we remove hamilton from the case chat
mantisshrimp69 2025-09-15 10:22 p.m.
He’s not intervening to my knowledge
mantisshrimp69 2025-09-15 10:23 p.m.
What would even be his argument to intervene? That DOS can tell people who something belongs to..?
meowiitten Server2025-09-16 02:31 a.m.
meowiitten Server2025-09-16 02:31 a.m.
meowiitten Server2025-09-16 02:32 a.m.
meowiitten Server2025-09-16 02:32 a.m.
meowiitten 2025-09-16 02:33 a.m.@cabot This is what I received
mantisshrimp69 2025-09-16 06:29 a.m.
We’re been over this tho
mantisshrimp69 2025-09-16 06:29 a.m.
Like that proves nothing
mantisshrimp69 2025-09-16 06:29 a.m.
I won’t rebut it because I don’t have to
mantisshrimp69 2025-09-16 06:29 a.m.
If he wants to claim ownership he needs to sue that way we can present a defense (thru which we will win)
huddy. 2025-09-16 11:42 a.m.@cabot Your Honor
huddy. 2025-09-16 11:42 a.m.
Do I have your permission to burst out laughing
huddy. 2025-09-16 11:42 a.m.
huddy. 2025-09-16 11:42 a.m.
So as we can see here, the Plaintiff has intended to mislead the court and done so by cutting a quote short.
huddy. 2025-09-16 11:50 a.m.
RobertSabbatini asked me to DM Nomadity to get RobertSabbatini access to the state bar legal advertisement channel, as he wished to post recruitment ads as he was the head of recruitment. The state bar previously knew he was the head of recruitment because they opened an investigation into him as he had been issuing numerous employment contracts to employees with illegal terms on them. Nevertheless, he asked me for a confirmation message to share with Mr. Nomadity, so I stated 'I, JamesMHamilton, registered owner of Hamilton & Wexler, hereby approve RobertSabbatini to represent the firm in the #legal-recruitment channel of the State Bar Association.' The fact that Plaintiff wants to use a statement, said by I, which explicitely states 'JamesMHamilton, Registered owner of H&W ', to claim that this is 'essentially a formal handover' is absolutely shambolic. Secondly, the Plaintiff has tried to mislead the court by cutting my statement short. My statement clearly refers to the fact that RobertSabbatini is only to represent the firm in a discord channel as he is in charge of recruitment. Instead, Plaintiff submitted to this courtroom 'in official State Bar communications', a misleading statement intended to make the court think that I made a statement allowing RobertSabbatini to represent the firm whilst in official talks with the State Bar, on an official ownership level. This is atrocious. Plaintiff then states 'He instructed me to inform the DoS business registry and Nomadity that (RobertSabbatini) was now the Managing Partner and firm representative so that they could update their records' .
huddy. 2025-09-16 11:50 a.m.
Not one clause of this is true. Before I sent the message saying that he could represent in the channel, I didn't realise Nomadity would accept that, so I just said 'just tell him that you're the new managing partner, tell him that i approve (of you to represent the channel)' . That passing statement, was solely intended to be represented in the channel. At no point did I ever mentioned the State Department business registry, or instruct him to inform the state department registry. He did that on his own accord without consulting me, and tricked them into thinking he was the new owner of the firm due to that one passing statement inteded for another purpose. They admitted this and apologised for their mistake and gave me back the firm after. Secondly, I never provided that statement 'so that they could update their records'. At no point were records ever discussed, and I never outlined that this admission should be used to amend any business records to list him as the owner of the firm.
huddy. 2025-09-16 11:51 a.m.@cabot Sir, these men have lied to the court
huddy. 2025-09-16 11:51 a.m.
and attempted to mislead your greatness
huddy. 2025-09-16 11:51 a.m.
they thought you were a weak fool
mantisshrimp69 2025-09-16 12:56 p.m.@cabot im not even going to read any of that
mantisshrimp69 2025-09-16 12:57 p.m.
I reiterate how sado is trying to desperately sway the court into a more favorable outcome by allowing Hamilton (who has no right to speak in these proceedings, and I don’t know why he was added?) to endlessly disrupt the case chat
mantisshrimp69 2025-09-16 12:58 p.m.
Hamilton does not have a right to own Clerion legal. That belongs squarely to RobertSabbatini and me. Even if he did, if he wants it, he has to sue us. This case is an administrative action that seeks to address the fact that DOS can’t adjudicate ownership—it is not an invitation for the court to then deliberate on that ownership. It has no jurisdiction to do so, because there is no controversy (Hamilton hasn’t filed a civil complaint).(edited)
huddy. 2025-09-16 01:56 p.m.
Wrong. The firm has never been yours, it has always been mine. RobertSabbatini gave you a firm which wasn't his to give. If he wants my firm, he can sue for it. He never had any claim to my firm, I never signed a contract giving him ownership of my firm and you can't show me a single contract even detailing him as a partner of the firm.
huddy.Wrong. The firm has never been yours, it has always been mine. RobertSabbatini gave you a firm which wasn't his to give. If he wants my firm, he can sue for it. He never had any cl...
mantisshrimp69 2025-09-16 02:14 p.m.
Who?
mantisshrimp69 2025-09-16 02:15 p.m.
Nobody asked you
mantisshrimp69 2025-09-16 02:15 p.m.
That’s false, but as I repeatedly keep telling you, I don’t have to rebut it
mantisshrimp69 2025-09-16 02:15 p.m.
This isn’t about who owns the firm, it’s about the fact that’s not for DOS to decide (especially in the way that they did)
mantisshrimp69 2025-09-16 02:16 p.m.
Because robert holds current ownership and is the de facto owner (whether legal or not) you will be the one that needs to sue, not the other way around
huddy. 2025-09-16 02:16 p.m.
Kid is either hella mad or think he such a sigma
mantisshrimp69 2025-09-16 02:16 p.m.
And I’ve been telling you this for ages so you might wanna act before laches attaches…
mantisshrimp69 2025-09-16 02:16 p.m.
Cool rhyme
huddy.Kid is either hella mad or think he such a sigma
mantisshrimp69 2025-09-16 02:16 p.m.
Okay
mantisshrimp69 2025-09-16 02:16 p.m.
??
mantisshrimp69 2025-09-16 02:17 p.m.
Womp womp bro cry me a river
mantisshrimp69 2025-09-16 02:18 p.m.
You have to sue to obtain equitable relief instead of asking some random ass executive agency that doesn’t know how to adjudicate controversies for it??? How terrible, gather the entire senate we must change the constitution this instant for this one crying baby
huddy. 2025-09-16 02:18 p.m. 
mantisshrimp69 2025-09-16 02:18 p.m.
You can act nonchalant all you want
mantisshrimp69 2025-09-16 02:19 p.m.
I hope you do enjoy it because when this is over you’re gonna be the one without a firm so
meowiitten 2025-09-16 02:30 p.m.@cabot
mantisshrimp69 2025-09-16 02:31 p.m.@cabot can you remove hamilton already
mantisshrimp69 2025-09-16 02:31 p.m.
Your honor
Chancellor Cabot ᴘᴄ 2025-09-16 02:37 p.m.
I hate this
Chancellor Cabot ᴘᴄ used /add
clerkFlow Bot2025-09-16 02:38 p.m. @cabot has added @k to the case channel.
Case Modified
Chancellor Cabot ᴘᴄI hate this
mantisshrimp69 2025-09-16 02:38 p.m.
can you remove hamilton
mantisshrimp69 2025-09-16 02:39 p.m.
he's not a party
mantisshrimp69 2025-09-16 02:39 p.m.
I don't know why he was added in the first plcae
meowiitten 2025-09-16 02:39 p.m.
Let me look back at the arguments and see if I need to do something
Chancellor Cabot ᴘᴄ 2025-09-16 02:40 p.m.
Okay how about you challenge the merits of the DOS decision to register the business to Hamilton rather than the procedure(edited)
Chancellor Cabot ᴘᴄOkay how about you challenge the merits of the DOS decision to register the business to Hamilton rather than the procedure(edited)
mantisshrimp69 2025-09-16 02:40 p.m.
Respectfully your honor
mantisshrimp69 2025-09-16 02:40 p.m.
Doing that would be impertinent
mantisshrimp69 2025-09-16 02:40 p.m.
This is not about that
mantisshrimp69 2025-09-16 02:41 p.m.
The court has no jurisdiction to oversee that as it stands either
Chancellor Cabot ᴘᴄ 2025-09-16 02:41 p.m.
It's a factual determination as to whether the agency acted arbitrarily and capriciously
huddy. 2025-09-16 02:41 p.m.
Your Honor just confirming you read my messages exposing the npz fella for lying, sorry for interrupting.
Chancellor Cabot ᴘᴄ 2025-09-16 02:41 p.m.
Yes thank you
Chancellor Cabot ᴘᴄ used /remove
clerkFlow Bot2025-09-16 02:41 p.m. @cabot has removed @huddy. from the case channel.
Case Modified
Chancellor Cabot ᴘᴄIt's a factual determination as to whether the agency acted arbitrarily and capriciously
mantisshrimp69 2025-09-16 02:42 p.m.
It's really not
mantisshrimp69 2025-09-16 02:42 p.m.
the agency has no jurisdiction to hear that regardless
mantisshrimp69 2025-09-16 02:42 p.m.
even if Hamilton had the most utmost and absolute ownership rights to Clerion, that still wouldn't matter
mantisshrimp69 2025-09-16 02:42 p.m.
the fact is if Hamilton wants the business he has to sue for it, and only then (a controversy being established) can the court adjudicate on the matter of ownership
mantisshrimp69 2025-09-16 02:43 p.m.
In that scenario, we will win, because rightfully the firm belongs to Robert and me
Chancellor Cabot ᴘᴄ 2025-09-16 02:43 p.m.
I'm not satisfied this court has jurisdiction over this dispute the way you've presented it to me
Chancellor Cabot ᴘᴄI'm not satisfied this court has jurisdiction over this dispute the way you've presented it to me
mantisshrimp69 2025-09-16 02:44 p.m.
can you elaborate
Chancellor Cabot ᴘᴄ 2025-09-16 02:47 p.m.
The suggestion that an agency exercising sound judgment and evaluating whether the facts demonstrate one person or the other person owns a business is not in their discretion and invokes SOP concerns is very far fetched
Chancellor Cabot ᴘᴄ 2025-09-16 02:48 p.m.
The proper method by which you challenge this is arguing the agency acted arbitrarily and capriciously BECAUSE THE FACTS DEMONSTRATE THAT YOU ARE THE OWNER not the other party
Chancellor Cabot ᴘᴄ 2025-09-16 02:48 p.m.
You've got this the whole wrong way round(edited)
mantisshrimp69 2025-09-16 02:48 p.m.
sorry Im
mantisshrimp69 2025-09-16 02:48 p.m.
doing like 30 things at once
Chancellor Cabot ᴘᴄThe suggestion that an agency exercising sound judgment and evaluating whether the facts demonstrate one person or the other person owns a business is not in their discretion and i...
mantisshrimp69 2025-09-16 02:48 p.m.
it's not far fetched
mantisshrimp69 2025-09-16 02:48 p.m.
they literally are not granted that authority
mantisshrimp69 2025-09-16 02:49 p.m.
their authority is outlined by statute
Chancellor Cabot ᴘᴄThe proper method by which you challenge this is arguing the agency acted arbitrarily and capriciously BECAUSE THE FACTS DEMONSTRATE THAT YOU ARE THE OWNER not the other party
mantisshrimp69 2025-09-16 02:49 p.m.
if DOS had jurisdiction to adjudicate...yes
mantisshrimp69 2025-09-16 02:49 p.m.
but they don't
Chancellor Cabot ᴘᴄ 2025-09-16 02:49 p.m.
They're not adjucating anything
Chancellor Cabot ᴘᴄ 2025-09-16 02:49 p.m.
They're deciding who to register
mantisshrimp69 2025-09-16 02:49 p.m.
They're deciding who owns private property
mantisshrimp69 2025-09-16 02:49 p.m.
Their decision clearly says they determined the business belongs to hamilton
Chancellor Cabot ᴘᴄ 2025-09-16 02:50 p.m.
The ability to register people requires critical thinking skills and using fact based judgment, if you're challenging that fact based judgment then this should be a challenge to whether they acted arbitrarily or capriciously
mantisshrimp69 2025-09-16 02:50 p.m.
They weren't registering
Chancellor Cabot ᴘᴄ 2025-09-16 02:50 p.m.
No they decided who owned the property for the purposes of business registration
mantisshrimp69 2025-09-16 02:51 p.m.
business registration is not determined like that in DOS
Chancellor Cabot ᴘᴄ 2025-09-16 02:51 p.m.
So the DOS did not make this decision about ownership in order to decide who was the registered owner of the business?
mantisshrimp69 2025-09-16 02:51 p.m.
correct
mantisshrimp69 2025-09-16 02:51 p.m.
not solely
meowiitten 2025-09-16 02:51 p.m.@mantisshrimp69 Hypothetically, if you were awarded your first claim for relief, James could not sue Clerion in the future to take ownership of it, right?
mantisshrimp69 2025-09-16 02:51 p.m.
Yes, he could
meowiitten 2025-09-16 02:51 p.m.
DOS would be enjoined from transferring it back to him
mantisshrimp69 2025-09-16 02:52 p.m.
No
meowiitten 2025-09-16 02:52 p.m.
I see
mantisshrimp69 2025-09-16 02:52 p.m.
They would be enjoined from making decisions of fact and law
meowiitten 2025-09-16 02:52 p.m.
Oh that's retarded
mantisshrimp69 2025-09-16 02:52 p.m.
when it doesn't pertain to either registration or commercial regulations
mantisshrimp69 2025-09-16 02:52 p.m.
WHEN IT DOESNT pertain to either registration or commercial regulations
mantisshrimp69 2025-09-16 02:52 p.m.
ownership and registration is different
mantisshrimp69 2025-09-16 02:52 p.m.
they REGISTER a REPRESENTATIVE that the company itself specifies (most often, the owner). they can't tell you who OWNS it, that's a matter of law and those facts are outside their jurisdiction to hear
Slout 2025-09-16 02:53 p.m.
if the owner didn't clearly specify someone to represent that company then that someone shouldn't be representing it...
mantisshrimp69 2025-09-16 02:54 p.m.
sure
mantisshrimp69 2025-09-16 02:54 p.m.
in that scenario (which is not what happened, because the firm specified Robert as the one to be the representative)
mantisshrimp69 2025-09-16 02:54 p.m.
you COULD have a hearing and determine, given due process, who it should be registered to
mantisshrimp69 2025-09-16 02:54 p.m.
that's your authority, yes
mantisshrimp69 2025-09-16 02:54 p.m.
you still can't hold a hearing and "investigation" to determine who OWNS a particular piece of private property
mantisshrimp69 2025-09-16 02:55 p.m.
those are two separate things @cabot
Chancellor Cabot ᴘᴄ 2025-09-16 02:56 p.m.
How can they be prohibited from making decisions of fact and law
Chancellor Cabot ᴘᴄ 2025-09-16 02:56 p.m.
That's stupid
Chancellor Cabot ᴘᴄ 2025-09-16 02:56 p.m.
Agencies need to be able to make decisions of fact in order to fulfil their basic function
Chancellor Cabot ᴘᴄ 2025-09-16 02:56 p.m.
That doesn't need to be explicit
mantisshrimp69in that scenario (which is not what happened, because the firm specified Robert as the one to be the representative)
Slout 2025-09-16 02:56 p.m.
the investigation has found that james hamilton never expressed the intent to have robert represent the firm to the dos
Chancellor Cabot ᴘᴄ 2025-09-16 02:57 p.m.
Where is our administrative procedures act
Chancellor Cabot ᴘᴄWhere is our administrative procedures act
meowiitten 2025-09-16 02:58 p.m.
We do not have one
Chancellor Cabot ᴘᴄ 2025-09-16 02:58 p.m.
I thought Krabz literally showed me it before
mantisshrimp69 2025-09-16 02:58 p.m.
we don't have an APA
mantisshrimp69 2025-09-16 02:58 p.m.
unfortunately
Chancellor Cabot ᴘᴄ 2025-09-16 02:58 p.m.
We were talking about the arbitrary and capricious standard and how he basically stole from RW
Chancellor Cabot ᴘᴄ 2025-09-16 02:58 p.m.
-_-
Chancellor Cabot ᴘᴄHow can they be prohibited from making decisions of fact and law
mantisshrimp69 2025-09-16 02:59 p.m.
that's not what I said
mantisshrimp69 2025-09-16 02:59 p.m.
DOS can make decisions of fact and law when it pertains to either REGISTRATION or COMMERCIAL REGULATIONS
mantisshrimp69 2025-09-16 02:59 p.m.
this pertained to neither
mantisshrimp69 2025-09-16 02:59 p.m.
it boiled down to "who owns this"
mantisshrimp69They would be enjoined from making decisions of fact and law
Chancellor Cabot ᴘᴄ 2025-09-16 02:59 p.m.
Am I imagining things or what
Chancellor Cabot ᴘᴄAm I imagining things or what
mantisshrimp69 2025-09-16 03:00 p.m. 
mantisshrimp69 2025-09-16 03:00 p.m.
said it twice btw
Chancellor Cabot ᴘᴄ 2025-09-16 03:00 p.m.
So the DOS determined ownership with no relation whatsoever for the purpose of registration?
Chancellor Cabot ᴘᴄ 2025-09-16 03:01 p.m.
They didn't need to update their registry to show the owner nor did they need to re-register with updated ownership?
meowiitten 2025-09-16 03:01 p.m.
Let me just link what James was talking about the registry and the trademark
mantisshrimp69 2025-09-16 03:01 p.m.
they also changed the name of the firm
mantisshrimp69 2025-09-16 03:01 p.m.
back
meowiitten 2025-09-16 03:01 p.m.Associated Goods or Services: Law/Legal Firm
Intellectual Property Owner: jamesmhamilton
Type: Word Mark(s)
Issuing Authority: minh1ebm
Issued Date: 3/09/2025
Expiration Date: 3/03/2026Business Name: Hamilton & Wexler
Business Owner(s): JamesMHamilton
Business Description: Hamilton & Wexler is a prestigious city law firm headquartered in Lander, Clark County. Established in early 2002 by lawyer and politician James Monroe Hamilton, H&W offers premium legal services at low fees, practicing and advising in all areas ...
https://trello.com/c/nksKiC9j/1130-tm-3032-trademark-word-marks
https://trello.com/c/jJZkyvCi/529-hamilton-wexler
https://trello.com/c/jJZkyvCi/529-hamilton-wexler
Labels
Status: ActiveComments
5Labels
Type: Limited Liability Company, Status: Activemantisshrimp69 2025-09-16 03:01 p.m.
essentially saying we didn't have the authority to change it
mantisshrimp69 2025-09-16 03:01 p.m.
why wouldn't we have the authority to change it unless we don't own it?
Chancellor Cabot ᴘᴄ 2025-09-16 03:02 p.m.
Yeah in which case you would challenge the agency's decision as arbitrary and capricious
mantisshrimp69 2025-09-16 03:02 p.m.
can this be resumed later? please
mantisshrimp69 2025-09-16 03:02 p.m.
I have
Chancellor Cabot ᴘᴄ 2025-09-16 03:02 p.m.
Well that's the dispute
mantisshrimp69 2025-09-16 03:02 p.m.
Im being
mantisshrimp69 2025-09-16 03:02 p.m.
arrested for something I didnt do
mantisshrimp69 2025-09-16 03:02 p.m.
rn
mantisshrimp69 2025-09-16 03:02 p.m.
so I kind of need to resume in a few minutes .
mantisshrimp69 2025-09-16 03:02 p.m.
is that Okay
Chancellor Cabot ᴘᴄ 2025-09-16 03:02 p.m.
Sigh
mantisshrimp69essentially saying we didn't have the authority to change it
Slout 2025-09-16 03:04 p.m.
we take those requests from the representatives of the firms (who are marked as "Owner: xyz" on the trello), if a person wasn't meant to be representing a firm in the first place then i think that person also wasn't meant to make any changes to the firm
Sloutwe take those requests from the representatives of the firms (who are marked as "Owner: xyz" on the trello), if a person wasn't meant to be representing a firm in the first place t...
mantisshrimp69 2025-09-16 03:04 p.m.@cabot
mantisshrimp69 2025-09-16 03:04 p.m.
Clearly by "representing" you mean "owning"
Chancellor Cabot ᴘᴄ 2025-09-16 03:06 p.m.
That's within the bounds of their discretion as to handle how agency and delegation works when handling those two core compentencies you described
Chancellor Cabot ᴘᴄ 2025-09-16 03:06 p.m.
In which case you would then challenge the decision as arbitrary and capricious because no reasonable person could come to the same conclusion with the facts in front of them
mantisshrimp69 2025-09-16 03:06 p.m.
this isn't that
mantisshrimp69 2025-09-16 03:07 p.m.
They determined verbatim who owned the business and who had the ability to make changes to it
mantisshrimp69 2025-09-16 03:07 p.m.
that was always the dispute
Chancellor Cabot ᴘᴄ 2025-09-16 03:07 p.m.
They determined who is the delegated representative to make representations to the agency in regards to those two core competencies they have
Chancellor Cabot ᴘᴄ 2025-09-16 03:07 p.m.
That had additional implications but they are secondary, not primary
Chancellor Cabot ᴘᴄ 2025-09-16 03:08 p.m.
Therefore that leads you to challenge the agency substantive decision
mantisshrimp69 2025-09-16 03:08 p.m.
The person who is allowed to make representations to the agency is the representative
mantisshrimp69 2025-09-16 03:08 p.m.
The representative is who the business chooses
Slout 2025-09-16 03:08 p.m.
also i think it is important to note, we never ordered mr robert to transfer any property associated with the firm (i.e. the discord server, or their mersea building) to mr hamilton, and i specifically advised mr hamilton to go to court for those
mantisshrimp69 2025-09-16 03:08 p.m.
Only somebody with authority in the business can choose the representative
Chancellor Cabot ᴘᴄ 2025-09-16 03:09 p.m.
Yes they have final say over who is the representative because that is their decision
Chancellor Cabot ᴘᴄ 2025-09-16 03:09 p.m.
You can then challenge that decision
mantisshrimp69 2025-09-16 03:09 p.m.
hm
Chancellor Cabot ᴘᴄ 2025-09-16 03:10 p.m.
If they decided the sky was blue tomorrow, the decision would not be for me to say they lacked the authority to declare the sky was blue when case law outlines the actual method to challenge the decision rests with whether that conclusion was arbitrary or capricious
Chancellor Cabot ᴘᴄ 2025-09-16 03:10 p.m.
Or reasonableness
Chancellor Cabot ᴘᴄ 2025-09-16 03:10 p.m.
pick whatever standard and find some common law grounding idgaf'
meowiitten 2025-09-16 03:11 p.m.
: /
mantisshrimp69 2025-09-16 03:14 p.m.@cabot
mantisshrimp69 2025-09-16 03:14 p.m.
that's if DOS' duty isn't ministerial
mantisshrimp69 2025-09-16 03:14 p.m.
I think it very much is
mantisshrimp69 2025-09-16 03:15 p.m.
they're supposed to keep, on paper, records. they're record keepers. that's it
mantisshrimp69 2025-09-16 03:15 p.m.
their authority to revert, deny, etc. things like filings by a representative hinges on that it actually be declared illegal by a court of law, which requires a lawsuit
mantisshrimp69 2025-09-16 03:15 p.m.
they cant decide themselves whether it's fraudulent or not
mantisshrimp69 2025-09-16 03:18 p.m.
"The Secretary of State shall handle the registration of business entities and intellectual properties within the State, ensuring that all necessary documents and information prerequisites are provided on the registration method." 5 M.S.C. 1 § 4501. The "registration method" refers to the initial registration for opening a business. Besides that, DOS cannot enforce any requirements or prerequisites for any sort of representation to them because their duty is ministerial
meowiitten 2025-09-16 03:27 p.m.@mantisshrimp69 Okay well if the DOS reverses their decision then you are essentially forcing them to go against a trademark that they registered
meowiitten 2025-09-16 03:27 p.m.
James has a trademark on all Clerion Legal stuff
meowiittenJames has a trademark on all Clerion Legal stuff
mantisshrimp69 2025-09-16 03:54 p.m.
The trademark belongs to Clerion
mantisshrimp69 2025-09-16 03:54 p.m.
Not Hamilton
mantisshrimp69 2025-09-16 03:54 p.m.
That would be an independent issue in registration. If James thinks to sue for that, he won’t win
mantisshrimp69 2025-09-16 03:54 p.m.
In fact, for that I might sue for declaratory judgment
mantisshrimp69 2025-09-16 03:54 p.m.
Thank you for bringing this to my attention
mantisshrimp69The trademark belongs to Clerion
meowiitten 2025-09-16 04:02 p.m. 
meowiitten 2025-09-16 04:02 p.m.
:/
meowiittenClick to see attachment.
mantisshrimp69 2025-09-16 05:33 p.m.
All H&W and Clerion logos belong to Clerion Legal
mantisshrimp69 2025-09-16 05:33 p.m.
It is an issue that we might rectify
mantisshrimp69 2025-09-16 05:33 p.m.
It’s clerical
mantisshrimp69 2025-09-16 05:33 p.m.
What exactly is your point
mantisshrimp69All H&W and Clerion logos belong to Clerion Legal
meowiitten 2025-09-16 05:34 p.m.
Are you saying the mark actually belongs to you that he registered on his own
mantisshrimp69 2025-09-16 05:34 p.m.
I’m saying what I’m saying
meowiitten 2025-09-16 05:34 p.m.
Well whatever
mantisshrimp69 2025-09-16 05:36 p.m.
Ok
mantisshrimp69 2025-09-16 05:36 p.m.
So you don’t have a point
mantisshrimp69 2025-09-16 05:36 p.m.
Great
mantisshrimp69So you don’t have a point
meowiitten 2025-09-16 05:39 p.m.
Well you're asking them to reverse a trademark decision...? Essentially that is what they're doing. And then they're going to be opening themselves up to litigation because you (and this is just going off of what I see), took the firm from James, and then started up Clerion, even though James holds all of the rights to Clerion by trademark
mantisshrimp69 2025-09-16 05:56 p.m.
1. We’re asking the court to reverse an unconstitutional ultra vires business registration decision, not trademark. The trademark issue is something you brought up, but it’s independent from this action and has nothing to do with it.
2. Who’s going to open themselves up to litigation? Me? DOS? Clerion? As a result of what? The Court’s decision?
3. So what? You’ve yet to explain how this is anything but irrelevant to this case…this is about how DOS can’t tell me who owns something.
2. Who’s going to open themselves up to litigation? Me? DOS? Clerion? As a result of what? The Court’s decision?
3. So what? You’ve yet to explain how this is anything but irrelevant to this case…this is about how DOS can’t tell me who owns something.
mantisshrimp69 2025-09-16 05:59 p.m.
4. If I want to “open myself up to litigation because I took the firm from James” what are you going to do about it? Is the Court, in your eyes, going to refuse to grant the order reversing because it somehow thinks it’s not in my best interests?
mantisshrimp69 2025-09-16 05:59 p.m.
And by the way I did not take the firm from James, thank you
Chancellor Cabot ᴘᴄ 2025-09-16 06:21 p.m.
Alright well I will dismiss this matter without prejudice or grant leave to present an amended complaint
Chancellor Cabot ᴘᴄAlright well I will dismiss this matter without prejudice or grant leave to present an amended complaint
mantisshrimp69 2025-09-16 06:35 p.m.
So you’re saying then that DOS’ duty is not ministerial
mantisshrimp69 2025-09-16 06:35 p.m.
Otherwise what’s the basis
Chancellor Cabot ᴘᴄ 2025-09-16 06:44 p.m.
How is ministerial duty relevant her
Chancellor Cabot ᴘᴄ 2025-09-16 06:44 p.m.
e
mantisshrimp69that's if DOS' duty isn't ministerial
mantisshrimp69 2025-09-16 06:47 p.m.@cabot
mantisshrimp69 2025-09-16 06:48 p.m.
From the clear wording of the statute I think their duty in registration and record-keeping is ministerial
mantisshrimp69From the clear wording of the statute I think their duty in registration and record-keeping is ministerial
meowiitten 2025-09-16 07:18 p.m.1
Start getting pissed off at him that usually helps
1meowiittenStart getting pissed off at him that usually helps
mantisshrimp69 2025-09-16 07:19 p.m.
Yeah if I want a misdemeanor conviction
mantisshrimp69 2025-09-16 07:19 p.m.
Which I don’t have the privilege to get an insta nepo pardon for
mantisshrimp69 2025-09-16 07:19 p.m.
I chose to respect the court thank you
mantisshrimp69 2025-09-17 04:50 p.m.@cabot
mantisshrimp69 2025-09-17 04:50 p.m.
So
Chancellor Cabot ᴘᴄ 2025-09-17 04:59 p.m.
Refile the case with an amended complaint as suggested above or I can dismiss
Chancellor Cabot ᴘᴄRefile the case with an amended complaint as suggested above or I can dismiss
mantisshrimp69 2025-09-17 05:19 p.m.
Okay so it’s ministerial then
mantisshrimp69 2025-09-17 05:19 p.m.
Do you agree
mantisshrimp69 2025-09-17 05:19 p.m.
I’m trying to make sense of your opinion
Chancellor Cabot ᴘᴄ 2025-09-17 06:08 p.m.
Yes quite obviously
mantisshrimp69 2025-09-17 06:09 p.m.
Okay
mantisshrimp69 2025-09-17 06:09 p.m.
It is?
mantisshrimp69 2025-09-17 06:09 p.m.
Or did you mean to say it isn’t
mantisshrimp69 2025-09-17 06:09 p.m.
Sorry
Chancellor Cabot ᴘᴄ 2025-09-17 06:11 p.m.
A ministerial act is an act performed in a prescribed manner and in obedience to a legal authority, without regard to one’s own judgment or discretion. The distinction between ministerial acts and acts that are discretionary is often important to determine whether a public official is shielded by qualified immunity. Generally, ministerial acts are unshielded by qualified immunity, which protects only actions taken pursuant to discretionary functions. In other words, noncompliance with a ministerial duty bars qualified immunity.
Chancellor Cabot ᴘᴄ 2025-09-17 06:12 p.m.
The statute specifies those two functions as core to the DOS's functionality, how would they not be ministerial
Chancellor Cabot ᴘᴄ 2025-09-17 06:15 p.m.
They have to exercise discretion if they veer outside of those two purposes, the simple fact they veer outside of that doesn't make them ultra vires. There are implied powers that are secondary to those specified in the statute.
For example, if the statute specifies that the DOS will maintain a register of statewide businesses. That implies they will need to appoint staff upon whom that responsibility may be delegated, it implies that they must make objective determinations as to the information collected and how they collect, it implies that it be published etc
For example, if the statute specifies that the DOS will maintain a register of statewide businesses. That implies they will need to appoint staff upon whom that responsibility may be delegated, it implies that they must make objective determinations as to the information collected and how they collect, it implies that it be published etc
Chancellor Cabot ᴘᴄ 2025-09-17 06:15 p.m.
The simple fact that every subsidiary outcome is not specified does not render it ultra vires
Chancellor Cabot ᴘᴄ 2025-09-17 06:15 p.m.
They are implied
Chancellor Cabot ᴘᴄ 2025-09-17 06:17 p.m.
An example of ultra vires: President detaining citizens who speak ill of him. He isn't just without the power, but he is without that power often (but not always) because there is a positive law specifying against the exercise of that type of power, impliedly or explicitly.(edited)
mantisshrimp69 2025-09-17 06:21 p.m.
alright @cabot I will amend
mantisshrimp69 2025-09-17 06:22 p.m.
in our original complaint though we did also note a procedural due process violation
mantisshrimp69 2025-09-17 06:23 p.m.
I assume you factored that into your decision to have us amend or dismiss so that would also be insufficient in your eyes no?
Chancellor Cabot ᴘᴄ 2025-09-17 06:25 p.m.
sure but im not sure what the difference in relief awarded could be if you went with arbitrary and capricious alongside procedural dp
mantisshrimp69 2025-09-17 06:26 p.m.
I see it as
mantisshrimp69 2025-09-17 06:26 p.m.
I mean
mantisshrimp69 2025-09-17 06:26 p.m.
I think you agree the procedural due process thing isnt insufficient @cabot
mantisshrimp69 2025-09-17 06:26 p.m.
Maybe Im misreading it
mantisshrimp69 2025-09-17 06:26 p.m.
but in that case it would probably be best to proceed that way
mantisshrimp69 2025-09-17 06:27 p.m.
you'd reverse it, and then if DOS wants to in the future hold another hearing, and this time they don't have a procedural due process violation, then we can challenge as being arbitrary and capricious
mantisshrimp69 2025-09-17 06:27 p.m.
this is also already filed so we can just pick off where we left off
mantisshrimp69 2025-09-17 06:27 p.m.
I can show my evidence, call you a few witnesses . . .
mantisshrimp69 2025-09-17 06:27 p.m.
easy no?
mantisshrimp69I think you agree the procedural due process thing isnt insufficient @cabot
Chancellor Cabot ᴘᴄ 2025-09-17 06:29 p.m.
well if you're just going to proceed on that point then ill grant leave for you and the dos to engage in mediation through a hearing and keep this open
Chancellor Cabot ᴘᴄ 2025-09-17 06:29 p.m.
i dont see a need for this to go to trial if all it takes is talking about this and seeing if they arrive at the same unfavourable outcome
mantisshrimp69 2025-09-17 06:29 p.m.
it's not going to trial
mantisshrimp69 2025-09-17 06:29 p.m.
they're in default remember
mantisshrimp69 2025-09-17 06:29 p.m.
this is the default hearing that's it
Chancellor Cabot ᴘᴄ 2025-09-17 06:29 p.m.
oh yeah
mantisshrimp69 2025-09-17 06:29 p.m.
it's going to be really fast, in fact I could call everybody right now
mantisshrimp69 2025-09-17 06:29 p.m.
that is, if I even need all the witnesses I listed
Chancellor Cabot ᴘᴄ 2025-09-17 06:30 p.m.
but then the relief i order isnt really sufficient is it if im just saying hear everyone again in a hearing
Chancellor Cabot ᴘᴄ 2025-09-17 06:30 p.m.
and they likely arrive that the same decision
Chancellor Cabot ᴘᴄ 2025-09-17 06:30 p.m.
unless theyre suggesting their first decision was irrational
Chancellor Cabot ᴘᴄ 2025-09-17 06:30 p.m.
and thats not the suggestion im getting
Chancellor Cabot ᴘᴄ 2025-09-17 06:31 p.m.
i can do it if you want but i wont handle the case again after i finish this and if they provide an unfavourable decision(edited)
Chancellor Cabot ᴘᴄ 2025-09-17 06:31 p.m.
itll be chucked to judge awesomeplays or richo or some inactive pleb(edited)
mantisshrimp69 2025-09-17 06:31 p.m.
the pdp violation wasn't a trivial thing, it didn't let us counter the evidence. I think once we have an actually fair hearing, we will be able to sway DOS
mantisshrimp69 2025-09-17 06:31 p.m.
if they still don't, Ill sue again
mantisshrimp69 2025-09-17 06:33 p.m.
also I have a general concern
mantisshrimp69 2025-09-17 06:36 p.m.
DOS contacted us with this message:
This isn't really about who owns the business, but whether intent was there to transfer the representative status (as registered on the trello) from Hamilton to somebody else. They determined no; they never actually adjudicated on who owns the business, though. So the business still belonged to us, just that the representative was still Hamilton (which is different from ownership) and the communication to DOS by the prior representative, being void, was reversed. But we could still, in this scenario, ask DOS to change the representative, and given we own the firm, they should do so... right?
We have received a report with evidence that would suggest that the screenshots that you used to get the ownership of former Hamilton & Wexler transferred from JamesMHamilton onto you were taken out of context. We have received full screenshots and according to those, we believe that the original owner (JamesMHamilton) never actually expressed intent to transfer the ownership of the business, despite transferring the [D]iscord server (allegedly so you could manage the tickets more efficiently?). We have also received evidence that the change we made on our Commerce Trello was then also used to change the ownership of the firm in the [bar] Database. Is what I'm saying correct, or do you have anything that might suggest the opposite?This isn't really about who owns the business, but whether intent was there to transfer the representative status (as registered on the trello) from Hamilton to somebody else. They determined no; they never actually adjudicated on who owns the business, though. So the business still belonged to us, just that the representative was still Hamilton (which is different from ownership) and the communication to DOS by the prior representative, being void, was reversed. But we could still, in this scenario, ask DOS to change the representative, and given we own the firm, they should do so... right?
mantisshrimp69 2025-09-17 06:36 p.m.@cabot
mantisshrimp69 2025-09-17 06:37 p.m.
so perhaps Ive been looking at this all wrong and I could just ask them to change the representative
mantisshrimp69 2025-09-17 06:37 p.m.
would you agree
mantisshrimp69so perhaps Ive been looking at this all wrong and I could just ask them to change the representative
mantisshrimp69 2025-09-17 06:50 p.m.
if this is the case, Ill take that route
mantisshrimp69 2025-09-17 06:50 p.m.
it's what seems most likely now in hindsight
mantisshrimp69 2025-09-17 06:50 p.m.
if not, and Ill wait for your answer, Ill take my chances going only for the pdp violation
Chancellor Cabot ᴘᴄ 2025-09-18 07:30 a.m.
No
Chancellor Cabot ᴘᴄ 2025-09-18 07:30 a.m.
At the end of it they're deciding on who is the registered business owner because only then can that owner delegate someone
Chancellor Cabot ᴘᴄAt the end of it they're deciding on who is the registered business owner because only then can that owner delegate someone
mantisshrimp69 2025-09-18 08:02 a.m.
That’s not what they decided on though
mantisshrimp69 2025-09-18 08:02 a.m.
Checking the evidence
mantisshrimp69 2025-09-18 08:02 a.m.
They decided that the original stuff was void that’s it
mantisshrimp69 2025-09-18 08:02 a.m.
We’ve looked at this all wrong
Chancellor Cabot ᴘᴄ 2025-09-18 08:04 a.m.
Inherently they looked at who was delegated by the owner (James), they relied on the owner regarding who he delegated as his representative or if it was misrepresented to them
mantisshrimp69 2025-09-18 08:05 a.m.
No I think they accepted the ownership change but they thought that him transferring representative status to Robert was improper and reversed it
Chancellor Cabot ᴘᴄ 2025-09-18 08:05 a.m.
So who is the owner recognised by DOS
mantisshrimp69 2025-09-18 08:05 a.m.
I don’t think DOS recognizes an owner
mantisshrimp69 2025-09-18 08:05 a.m.
They leave that to the law
mantisshrimp69 2025-09-18 08:05 a.m.
They only care abt who the rep to them is
mantisshrimp69 2025-09-18 08:06 a.m.
And they found that Robert isn’t
Chancellor Cabot ᴘᴄ 2025-09-18 08:06 a.m.@Slout Who is the recognised owner
Chancellor Cabot ᴘᴄ 2025-09-18 08:06 a.m.
The recognised owner is the only person who can delegate a representative to the agency so it matters who it is and who the DOS recognises as such
Chancellor Cabot ᴘᴄ 2025-09-18 08:07 a.m.
Unless the incorporated articles suggest there is a different method of selecting a representative to the agency
Chancellor Cabot ᴘᴄThe recognised owner is the only person who can delegate a representative to the agency so it matters who it is and who the DOS recognises as such
Slout 2025-09-18 08:13 a.m.
We believe that JamesMHamilton is the person authorised to represent and make decisions for Hamilton & Wexler
SloutWe believe that JamesMHamilton is the person authorised to represent and make decisions for Hamilton & Wexler
mantisshrimp69 2025-09-18 08:13 a.m.
That’s not what he’s asking
mantisshrimp69 2025-09-18 08:13 a.m.
He’s asking who you think the owner is, not the representative
Chancellor Cabot ᴘᴄUnless the incorporated articles suggest there is a different method of selecting a representative to the agency
Slout 2025-09-18 08:13 a.m.
To my knowledge, neither Hamilton & Wexler, nor Clerion Legal ever had those
mantisshrimp69 2025-09-18 08:13 a.m.
Do you
mantisshrimp69 2025-09-18 08:13 a.m.
Lorens
mantisshrimp69 2025-09-18 08:13 a.m.
Do you recognize who owns Clerion
mantisshrimp69 2025-09-18 08:13 a.m.
Or just who can make decisions (the representative)
mantisshrimp69 2025-09-18 08:14 a.m.
This is indicative that you only recognize the latter (cc @cabot )
mantisshrimp69Or just who can make decisions (the representative)
Slout 2025-09-18 08:17 a.m.
Most often the owner makes decisions and appoints the firm's representatives. I haven't really ever seen any other leadership arrangement but I am sure that those can exist. As found by our investigation, JamesMHamilton never expressed the intent to transfer the ownership of the firm onto RobertSabbatini, despite wanting him to represent the firm for the BAR.
Chancellor Cabot ᴘᴄ 2025-09-18 08:17 a.m.
Yeah but that makes 0 sense to do the latter, you have to recognise the legal owner as only they can delegate a representative
Chancellor Cabot ᴘᴄ 2025-09-18 08:18 a.m.
So James is the owner, you found that Robert was only a representative to the agency at James' discretion?
Chancellor Cabot ᴘᴄSo James is the owner, you found that Robert was only a representative to the agency at James' discretion?
Slout 2025-09-18 08:19 a.m.
We were under the belief that Robert was the owner at James' discretion until the investigation has found that this wasn't the case
Chancellor Cabot ᴘᴄ 2025-09-18 08:20 a.m.
Plus I'm not even sure I can allow you to make representations as to procedural due process, you earlier argued that the agency is devoid of the ability to adjudicate the matter. You're essentially asking through the PDP claim for the agency to adjudicate but with new evidence and your representations included, that should be estopped under judicial estoppel @mantisshrimp69
Slout 2025-09-18 08:20 a.m.
Nor did he want Robert to represent the firm to the DOS in any way, according to what we found in our investigation(edited)
SloutWe were under the belief that Robert was the owner at James' discretion until the investigation has found that this wasn't the case
Chancellor Cabot ᴘᴄ 2025-09-18 08:20 a.m.
Well how can that be the case
Chancellor Cabot ᴘᴄ 2025-09-18 08:20 a.m.
Only one person can be the owner
Chancellor Cabot ᴘᴄ 2025-09-18 08:21 a.m.
Then that owner can delegate a representative
Chancellor Cabot ᴘᴄ 2025-09-18 08:21 a.m.
Or representatives
Chancellor Cabot ᴘᴄWell how can that be the case
Slout 2025-09-18 08:21 a.m.
As in, we believed that James transferred ownership to Robert
Chancellor Cabot ᴘᴄ 2025-09-18 08:21 a.m.
Well then Robert assumes absolute legal control if ownership transferred and you believe that
Chancellor Cabot ᴘᴄ 2025-09-18 08:21 a.m.
Then Robert can appoint and delegate a representative
Chancellor Cabot ᴘᴄ 2025-09-18 08:21 a.m.
Either himself or someone else to the agency
Slout 2025-09-18 08:22 a.m.
The investigation has found that James never transferred the ownership to Robert or to anyone else
Slout 2025-09-18 08:22 a.m.
Which I believe is the main point of this lawsuit
Chancellor Cabot ᴘᴄ 2025-09-18 08:22 a.m.
So the position of the DOS is that James is the legal owner of the business and any transfer to Robert was lacking in intent(edited)
Chancellor Cabot ᴘᴄ 2025-09-18 08:22 a.m.
?
Slout 2025-09-18 08:22 a.m.
Correct
Chancellor Cabot ᴘᴄ 2025-09-18 08:23 a.m.
Okay then I'm not sure what you
Chancellor Cabot ᴘᴄ 2025-09-18 08:23 a.m.
're challenging npz
Chancellor Cabot ᴘᴄ 2025-09-18 08:23 a.m.
You can only challenge the agency's determination as to who they believe is the registered legal owner, that is the chief issue rather than who they believe the representative is(edited)
Chancellor Cabot ᴘᴄ 2025-09-18 08:24 a.m.
Who the representative is is irrelevant, the owner under the law of agency has absolute discretion to appoint and delegate power to representatives
Chancellor Cabot ᴘᴄ 2025-09-18 08:24 a.m.
Any legal challenge to who the representative is is not addressing the issue
Chancellor Cabot ᴘᴄ 2025-09-18 08:25 a.m.
Either Robert is the legal owner and he can appoint a representative or James is the legal owner and he can appoint a representative
Chancellor Cabot ᴘᴄ 2025-09-18 08:25 a.m.
The fact that James appointed Robert as a representative entitles him to absolutely no claim in law to the business
Chancellor Cabot ᴘᴄThe fact that James appointed Robert as a representative entitles him to absolutely no claim in law to the business
Slout 2025-09-18 08:28 a.m.
From what we believe, James never actually appointed Robert as a representative to the DOS either, only to the Bar
Slout 2025-09-18 08:29 a.m.
The Bar has its own registry of law firms and they are able to recruit in there
mantisshrimp69 2025-09-18 08:37 a.m.
When I get out of school
mantisshrimp69 2025-09-18 08:37 a.m.
I answer
Chancellor Cabot ᴘᴄ 2025-09-18 08:51 a.m.
I see
mantisshrimp69 2025-09-19 06:20 p.m.@cabot
mantisshrimp69 2025-09-19 06:20 p.m.
The fact that DOS has a ministerial record-keeping duty does not mean they get to hold hearings to determine stuff
mantisshrimp69 2025-09-19 06:20 p.m.
Their duty is purely ministerial
mantisshrimp69 2025-09-19 06:20 p.m.
If there is a dispute, they should defer the person making the complaint to the courts
Chancellor Cabot ᴘᴄPlus I'm not even sure I can allow you to make representations as to procedural due process, you earlier argued that the agency is devoid of the ability to adjudicate the matter. Y...
mantisshrimp69 2025-09-19 06:21 p.m.
judicial estoppel only applies if I win, or at least if I get something out of making the argument
mantisshrimp69 2025-09-19 06:21 p.m.
it was rejected by the court so estoppel wouldn't apply
mantisshrimp69 2025-09-20 01:24 p.m.@cabot
Chancellor Cabot ᴘᴄ 2025-09-20 03:30 p.m.
Okay are you going to fix what I said or not
Chancellor Cabot ᴘᴄ 2025-09-20 03:30 p.m.
I'm not going back and forth
mantisshrimp69 2025-09-21 05:13 p.m.@cabot I must recuse
mantisshrimp69 2025-09-21 05:13 p.m.
somebody else from clerion will be taking over
mantisshrimp69 2025-09-21 05:13 p.m.
Thank you
Chancellor Cabot ᴘᴄ 2025-09-21 05:17 p.m.
Case is given to @Brenda
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Chambers of Judge Popplewell1
judicialFLOW Bot2025-09-22 01:39 a.m.Requester: @Slout
Party:Defendant Lorens20181
Channel:npz_v-robertsabbatini-v-mayflower-department-of-state-lorens20181
A Magistrate Judge or higher may approve or deny below. 
Request ID: 49e2e2a432ed4567b9621a6e0e472dc5 Approve Deny
(edited)
Appearance Request
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Channel:
A Magistrate Judge or higher may approve or deny below.
Status
robert 2025-09-22 02:05 a.m.
Your Honor, I’m the one of the plaintiff's. I no longer wish to pursue this case and hereby voluntarily dismiss it without prejudice if that's okay. To my knowledge, no counterclaim is pending that would prevent dismissal. I’d appreciate the docket reflecting dismissal and any upcoming settings being vacated.
@Brenda
robertYour Honor, I’m the one of the plaintiff's. I no longer wish to pursue this case and hereby voluntarily dismiss it without prejudice if that's okay. To my knowledge, no counterclai...
mantisshrimp69 2025-09-22 06:02 a.m.
Ohh nooo
judicialFLOW Bot2025-09-22 01:25 p.m.@Slout appears for Defendant Lorens20181 (approved by @Brenda ).
judicialFLOW pinned a message to this channel.2026-01-18 02:59 p.m.
Brenda 2025-09-22 01:32 p.m.@robert @Slout @meowiitten @mantisshrimp69
MINUTE ORDER: Pursuant to Plaintiff RobertSabbatini's Mayf. R. Civ. P. 31(a) notice of dismissal, it is ORDERED that all claims by RobertSabbatini in the above Complaint are dismissed without prejudice. Signed by District Judge Brenda Popplewell (Entered: 09/22/2025).(edited)
MINUTE ORDER: Pursuant to Plaintiff RobertSabbatini's Mayf. R. Civ. P. 31(a) notice of dismissal, it is ORDERED that all claims by RobertSabbatini in the above Complaint are dismissed without prejudice. Signed by District Judge Brenda Popplewell (Entered: 09/22/2025).(edited)
krabz used /transcript
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krabz 2025-10-04 04:02 p.m.
oh nvm npz still exists
Brenda 2025-11-16 10:01 a.m.@Prothonotary's Office Dismissed w/o prejudice for failure to prosecute. Archive
Your Local Dreamer used /transcript
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Volume XIIIYour Local Dreamer 2025-11-16 10:07 a.m.
done @Brenda
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